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REMIT: Practical implications of U.S. decertification of JCPOA and new sanctions

23 October 2017

Client Alert | Iran | Sanctions & Compliance

OVERVIEW

On October 13, 2017 the incumbent U.S. President, speaking in a televised address delivered from the White House, announced that he refused to re-certify Iran's compliance with the nuclear deal (“JCPOA”) and thereby authorized the U.S. Treasury to sanction the Islamic Revolutionary Guard Corps (“IRGC”) as supporters of terrorism as well as to place new sanctions on various Iranian entities for their alleged involvement in actions that the president described as running against U.S. national interest.

JCPOA: FUTURE IN PERIL?

President Trump, despite repeated verifications by the International Atomic Energy Agency ("IAEA") attesting to Iran’s full compliance with the JCPOA and despite many high-ranking U.S. officials, including the Secretary of State and Defense Secretary, confirming the same, made clear in his address that come the official deadline of October 15, he would refrain from certifying to the U.S. Congress that Iran is complying with the terms of the JCPOA.

The certification requirement to be made every 90 days is bestowed upon the president by the Iran Nuclear Agreement Review Act ("INARA"), a legislative move by Congress to ensure it plays a role in deciding the fate of the JCPOA.